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PEOPLE v. SULLIVAN

167 A.D.2d 564 (1990)

The People of the State of New York, Respondent, v. Arthur Sullivan, Appellant

Appellate Division of the Supreme Court of the State of New York, Second Department.

November 26, 1990

Ordered that the judgment is affirmed.

The defendant argues that the court should have granted his motion for a mistrial when it was discovered that some of the jurors viewed a newspaper article and accompanying photograph reporting the events at trial the previous day. We disagree.

The Court of Appeals has observed that "`[b]ecause juror misconduct can take many forms, no ironclad rule of decision is possible. In...

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